Does your company trade in and provide virtual currency, like bitcoins? Or are you a custodial wallet provider? Then you have to register with De Nederlandsche Bank (DNB). Virtual currency (also called ‘crypto coins’) is vulnerable to financial crime. This article tells you how to register as a broker.
On this page
Why must you register?You must register because digital currencies are used by criminals to launder money, and to finance terrorism. When you register, you come under the supervision of DNB. DNB monitors if you abide by the legislation to combat money laundering. It is your responsibility to check transactions for unusual activities, and to perform a background check of your customers. DNB oversees how you do this. For instance, by researching your company.
No registration? No servicesIt is illegal to provide services for exchanging or storing crypto coins. Registration also makes you trustworthy in the eyes of customers and suppliers.
Who has a duty to register?The duty to register applies to all brokers in the Netherlands who exchange legal tender, such as euros and dollars, for crypto currency, and the other way around. The registration duty also applies to custodial wallet providers. Foreign crypto services brokers who want to trade in the Netherlands must also register.
How do you prepare your registration application?To register, you must file the following information with DNB:
- General company information, including articles of association (in Dutch) and KVK extract
- A company plan, outlining the strategy, and overview of the activities and a SWOT analysis
- Composition of the board, including organisational and control structure
- Delineation of the business operations and management, including rules and regulations, audit, notification procedure, secondment, training, and education
- Description of business operations
- A file per board member, demonstrating their fitness and propriety